DEFINITIONS & ROLES
Personal Data refers to any information that is identifiable to specific individuals or by which specific individuals can be identified, such as name, identification numbers, email address, mailing address, phone numbers, or other personal characteristics or attributes. Personal Data does not include anonymized information that is not identifiable to a specific individual. Data Subject refers to the individual to whom the Personal Data refers. Data Controller refers to the owner of the Personal Data that determines the purposes and means of its processing, which in most cases (including when Personal Data is entered into the customer’s instance of the VMS or customer’s Direct-Sourcing Solution Private Talent Pool) is the customer of Beeline.
Beeline acts as Data Controller only in the limited circumstance where it determines the means and purposes of processing the Personal Data, which is limited to when Beeline collects personal data for marketing and product improvement purposes.
Customer Confidential Information refers to non-public information of Beeline customers (for which the Beeline customer is the Data Controller) and includes personal information submitted to Beeline for processing in the VMS, Direct-Sourcing Solution, or other Beeline application.
Processor refers to the entity that processes Personal Data on behalf of a Data Controller. When the Data Controller is a Beeline customer using Customer Confidential Information, Beeline performs the role of Processor.
Access: Data Subjects will be granted access to the Personal Data related to them as directed by the Data Controller and will be able to submit corrections to the information where the Data Subject believes it to be inaccurate (see “Inquiries” below). Corrections will be subject to verification and acceptance by the Data Controller.
Data Integrity and Purpose Limitation: Beeline will use Personal Data for the purpose of processing it on behalf of and as directed by Beeline customers as Data Controller, or in the limited circumstances where Beeline is the Data Controller for marketing or product improvement purposes. In the event that a complaint is received, Beeline will take steps to ensure that the Personal Data is accurate and current or will refer you to the Data Controller as appropriate.
Onward Transfer and Choice: With respect to Customer Confidential Information where Beeline is the Processor, Beeline will not transfer Personal Data to third parties, other than the Data Controller or their designees and third parties who perform certain services for Beeline. Third party service providers to Beeline agree to maintain appropriate procedures to safeguard the Personal Data and use it only for the purposes of providing services to Beeline.
Where Beeline is the Data Controller, Beeline agrees to maintain appropriate procedures to safeguard the Personal Data and use it only for the purposes described herein. If Beeline shares Personal Data with a third-party service provider that processes the data solely on Beeline’s behalf and under Beeline’s instructions, then Beeline will be liable for that third party’s processing of Personal Data in violation of the Principles, unless Beeline can prove that we are not responsible for the event giving rise to the damage.
In the event that Beeline receives a lawful request to disclose personal information by public authorities, including to meet national security or law enforcement needs, Beeline will comply with the request.
Type and Purpose of Information Processed by Beeline. As Data Processor, Beeline receives and processes Personal Data and Customer Confidential information from several sources in the normal course of business, including identification and contact information from customers, customers’ services suppliers, and Data Subjects, and business process information (such as regarding services procurement and payment processes) through the usage of the Beeline applications and communications among customer users and their services suppliers, the Data Subjects, Beeline users, and third-party users.
Beeline processes Customer Confidential Information for the purpose of providing our services to our customers, including tasks as directed or authorized by the Data Controller and in order to improve and develop our service offerings.
As Data Controller, Beeline processes transaction and information system usage information from Beeline applications and Beeline websites. This may include information obtained from cookies, which Beeline uses for a variety of reasons including remembering registration information, survey participation, and to autopopulate correspondence details. Beeline may directly collect Personal Data from you for contact or marketing purposes when you consent to such use in connection with registering for a Beeline event or webinar, create a profile in a Beeline application, visit a Beeline website, or otherwise submit Personal Data to Beeline. Marketing data collected may include contact information (name, email address, phone numbers), geographic information (state, country), billing information (billing address, payment card information), job data (title, company information, industry), emergency contact information, and other optional information you may provide (such as meal preferences, biographies, websites, social media accounts, and photographs). Beeline may also receive personal data about you from publicly available sources and third parties (including partners, analysts, social media, and hosts of events, conferences, and webinars) and may use such data for its legitimate interest of marketing purposes and based on your consent to such processing. Such personal data may be stored for such period of time until no longer required by Beeline to fulfill its purpose or until you request to have your personal data erased.
How This Information Is Used
Beeline uses Personal Data only for the purposes for which it was collected as described above. In addition, where Beeline acts as Data Processor, Beeline will perform legitimate and relevant tasks as directed or authorized by the Data Controller.
In the normal course of business, Personal Data and Customer Confidential information is processed by Beeline and via third parties who are contracted to provide certain services to Beeline or our customers. Personal Data submitted in connection with Beeline’s Direct-Sourcing Solution may be provided to third parties including Beeline’s customers or their designees. Personal Data may also be transferred to third parties of the Data Controller and their authorized agents or designees in the course of performing the process management services.
With respect to marketing information of which Beeline is the Data Controller, recipients of your Personal Data include Beeline and its affiliates (which may be located in the European Union, UK, Australia, or the United States) as well as sponsors of webinars or events for which you register and third parties engaged to perform services for Beeline, such as marketing research and automation (which may be located in and involve data transfers to such countries without an adequacy decision pursuant to the Standard Contractual Clauses or based on your consent).
Personal Data in Beeline’s possession is protected by its Information Systems Security Policy, which is designed to prevent unauthorized disclosure, misuse, or alteration of Personal Data. The Information Systems Security Policy includes confidentiality procedures applicable to all Beeline personnel, security requirements for physical and electronic security, and compliance policies and procedures for information handling. All Beeline personnel are required to acknowledge understanding of the Information Systems Security Policy, and adherence is enforced.
ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS
Where Beeline is Processor (including with respect to our processing of Customer Confidential Information), Beeline is a Service Provider to our customers. In its role as a Service Provider, Beeline does not sell Customer Confidential Information or Personal Data of Consumers (as defined by the California Consumer Protection Act) and does not retain, use, or disclose Personal Data for any purpose other than providing the services to our customers.
, via telephone at +1-904-527-5235, or via mail to Beeline at 12724 Gran Bay Parkway West, Suite 200, Jacksonville, Florida 32258, USA. Data Subjects in the European Union may also contact Beeline’s Local Representative (Beeline.com, Ltd.) via email at LocalRepresentative@beeline.com or by mail to Beeline at 80 Cannon Street, 7th Floor, London, EC4N 6HL.
For inquiries from Data Subjects about their Personal Data, Data Subjects should contact the Data Controller. Where a Data Subject instead submits an inquiry to Beeline and Beeline is not the Data Controller, Beeline will forward the inquiries to the appropriate Data Controller and assist with resolving the inquiry, including providing access to the Personal Data and correcting any errors in cooperation with the Data Controller.
Where Beeline is the Data Controller and to the extent the EU General Data Protection Regulation applies to you: (i) you may request from Beeline access to, rectification, erasure, or restriction of processing concerning your personal data; (ii) you have the right to object to the processing, the right to data portability, and the right to lodge a complaint with a supervisory authority; and (iii) you may contact Beeline regarding the source of any third party which provided your personal data to Beeline. With respect to such marketing data, you may withdraw your consent at any time by unsubscribing, updating your email preferences, or contacting Beeline to request erasure of your personal data. In the event you withdraw your consent or decline to provide any required personal data, you will not be able to receive future communications, register for events/webinars, download website content, or participate in the Beeline Community or other services offered by Beeline (including Beeline’s Direct-Sourcing Solution).
ALTERNATIVE DISPUTE RESOLUTION (ADR)
In compliance with the Privacy Shield Principles, Beeline commits to resolve complaints about our collection or use of your Personal Data. Individuals with inquiries regarding our Privacy Shield policy or complaints regarding the handling of your personal information should contact firstname.lastname@example.org
Beeline has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please email email@example.com
for more information. The services of JAMS are provided at no cost to you. To learn more about JAMS, click here
. To learn more about binding arbitration under the EU-U.S. Privacy Shield regulation, click here
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If you want to know more about our commitment to Privacy, please contact us at firstname.lastname@example.org